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his Court. 2 EFTA00676991 Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 3 of 12 PARTIES. 6. Plaintiff is an individual who is a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8.
o anyone—including Epstein's victims. As a consequence, the victims were not told about the NPA. 16. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey Epstein's victims (other than filed a petition to enforce her rights under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C.
is true—and that they were in fact true. Pursuant to the stipulated order entered by this Court on March 20, 2015 that appointed a Commissioner in the State of Colorado, Dershowitz served a subpoena for the production of documents and a videotaped deposition on Jane Doe No. 3. See Exhibit G.2. The subpoena seeks, a
the subpoena are at the very heart of this issue, which Edwards and Cassell have placed squarely in dispute. There simply is no basis for crediting Jane Doe's assertions of "irrelevance." Jane Doe No. 3's alternative argument — that she should be shielded from any discovery in this action because Dershow
founded pleading." Exhibit A, Compl. 17. Pursuant to the stipulated order entered by this Court on March 20, 2015 that appointed a Commissioner in the State of Colorado, Dershowitz served a subpoena for the production of documents and a videotaped deposition on Jane Doe No. 3. See Exhibit G.2 The subpoena seeks, am
the subpoena are at the very heart of this issue, which Edwards and Cassell have placed squarely in dispute. There simply is no basis for crediting Jane Doe's assertions of "irrelevance." Jane Doe No. 3's alternative argument — that she should be shielded from any discovery in this action because Dershowi
727 --- PAGE BREAK --- Case 1:15-cv-07433-LAP Document 1 Filed 09/21/15 Page 3 of 12 PARTIES 6. Plaintiff is an individual who is a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8.
Page: EFTA00015728 →her professional life to helping victims of sex trafficking. 26. On December 30, 2014, moved to join the on-going litigation previously filed by Jane Doe 1 in the Southern District of Florida challenging Epstein's non-prosecution agreement by filing her own joinder motion. 5 EFTA00015730 --- PAGE
Page: EFTA00015730 →Entities connected to both the State of Colorado and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSONJack Scarola
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSON
the United States District Court
ORGANIZATION
West Palm Beach
LOCATION
David Boies
PERSON
Colorado
LOCATIONSigrid McCawley
PERSON
Al Gore
PERSON
New York Daily News
ORGANIZATION
John Brockman
PERSON